Concept
An EU passport grants the right to live, work, and do business in twenty-seven countries, and demand for it remains high. There are essentially three routes: naturalization after several years of residence, investment, and descent. Each has its own timeline and cost, and over the past two years the rules have tightened noticeably. Understanding the differences helps choose a realistic route instead of the fastest one on paper.
Naturalization: Counted in Years
The most common path is to live in a country for a prescribed period on a legal basis and apply for citizenship. France and Germany require five years, and Germany abolished the accelerated three-year route in October 2025, leaving the baseline five. Spain formally requires ten years but reduces the term to two for citizens of Latin American countries, Andorra, the Philippines, Portugal, and several others. Almost everywhere you must actually live in the country, around 183 days per year, and demonstrate language proficiency: France is raising the requirement from B1 to B2 level as of January 2026.
Investment: First Residence, Then Naturalization
Portugal's and Greece's golden visas grant residence permits in exchange for investment, but the investment itself does not yet confer a passport. Residence merely starts the naturalization clock, and here too the rules have shifted: Portugal raised the term in October 2025 from five years to seven for EU citizens and Portuguese-speaking community countries, and to ten for all others. The only route that led directly to a passport through investment was Malta, but after the 2025 ECJ ruling in case C-181/23, classic citizenship-by-sale is closed, leaving only naturalization for exceptional merit.
Descent: Only for Certain Families
🔗 Related
Citizenship by Investment · Portugal Golden Visa · Greece Golden Visa · Second Passport and Plan B · Cyprus: non-dom
A number of EU countries recognize citizenship by descent if ancestors were their citizens. Conditions vary greatly from country to country and suit a narrow circle of families with documented lineage. For most high-net-worth clients without such roots, the practical choice comes down to naturalization and investment routes.
⚙️ Golden visa and citizenship are different rungs of the same ladder. Investment grants resident status, and a passport appears only after the naturalization period has been served with actual residence and language. The 2025 reforms in Portugal and Germany lengthened precisely the second rung, so the planning horizon should be counted in years.
🍓 Three families of routes lead to an EU passport: naturalization after five to ten years of residence, investment through a golden visa with subsequent naturalization, and descent for certain families. In 2025 Portugal extended naturalization to seven to ten years, Germany closed the three-year accelerated path, and Malta's direct citizenship-by-sale was terminated by an ECJ ruling. A route should be chosen with a multi-year horizon in mind.
This material is expert-analytical in nature and does not constitute individual legal or tax advice.
Key factual claims
- Related links: Citizenship by Investment · Portugal Golden Visa · Greece Golden Visa · Second Passport and Plan B · Cyprus: non-dom · ECJ case C-181/23 (EUR-Lex)